Proposed Correction to Chemical Nomenclature for Monomer Acid and Derivatives for TSCA Inventory Purposes

Résumé

An August 2, 1985 letter from EPA erroneously equates monomer acid and its derivatives with Tall Oil Fatty Acid (TOFA) and its corresponding derivatives for Toxic Substances Control Act (TSCA) Inventory purposes when, in fact, they are chemically distinct. As a result, many manufacturers of monomer acid derivatives have not submitted Premanufacture Notices (PMNs) under TSCA section 5, because the letter incorrectly indicated that monomer acid derivatives were covered by TOFA derivatives already on the Inventory. This notice proposes a correction to the 1985 letter on nomenclature of monomer acid and derivatives. With this proposed correction, monomer acid derivatives that are not on the Inventory would be considered new chemical substances under section 5 of TSCA.